The Financial Services and Markets Act 2000 (Regulated Activities etc.) (Amendment) Order 2025

This Order provides for certain “buy-now-pay-later” agreements which are currently exempt agreements within article 60F(2) of the Financial Services and Markets Act 2000 (Regulated Activities) Order 2001 (S.I. 2001/544) (“the Regulated Activities Order”) to become regulated credit agreements within the meaning of article 60B(3) of that Order. These agreements are referred to as “regulated deferred payment credit agreements” in this note. As a result, the regulated activities specified for the purposes of the Financial Services and Markets Act 2000 (c.8) (“FSMA”) by article 60B(1) (entering a regulated credit agreement) and (2) (exercise of lenders’ rights and duties under a regulated credit agreement) of the Regulated Activities Order will include those activities as they relate to regulated deferred payment credit agreements.